On 04/10/07, EPA OSC Smith and KDEP Superfund Branch staff investigated an abandoned former wood treating facility. EPA was first notified of this site in November 2006, when a concerned former employee notified the National Response Center concerning a potential release of wood treating chemicals. Inspection of the sump in the treatment building shows that a release of an unknown mixture possibly containing CCA constituents (chromium, copper, and arsenic) is imminent. There is known soil contamination at the site with total arsenic concentrations exceeding removal action levels.
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Due to the seriousness of the situation, the OSC initiated a time-critical removal action at the Site on July 18, 2007. The 1st phase of the removal action is short-term in nature and is designed to mitigate immediate threats. Work activities include securing the site, clearing debris, and arranging for the offsite disposal/treatment or legitimate reuse of wood treating solutions. This phase of work was completed on October 15, 2007, at a cost of approximately $365,000.
On September 24, 2007, EPA began a comprehensive sampling investigation at the site. Several hundred samples were collected using an X-Ray Fluorescence (XRF) analyzer to allow for real time measurements for arsenic and chromium in soils. Following the site investigation, EPA determined that additional soil removal and/or capping is required in order to prevent releases of hazardous substances to the environment. Results for the site investigation were reported in the Removal Site Evaluation Report prepared by Region 4 START contractor TN & Associates, Inc. Maximum arsenic and chromium concentrations detected onsite 15,000 ppm and 18,000 ppm, respectively.
A Ceiling Increase and Statutory Exemption Action Memorandum was approved in March 2008, establishing a budget of $2.27M for completion of the following tasks:
- Decommissioning the new treatment building and drip pad to demolish and decontaminate the pressure vessel, process tanks, and surrounding structures.
- Excavate contaminated soils on an adjacent residential property to mitigate direct contact threats.
- Restoration of disturbed areas, through backfill, grading, sodding and seeding, as needed.
On March 26, 2008, cleanup activities at the site resumed and the EPA fund-lead removal action was completed on October 23, 2008. During this phase of the cleanup, the treatment plant and drip pad built in the mid-80s was demolished, and this area of the site was re-graded, and hydroseeded. Over 60,000 gallons of CCA solutions were shipped offsite for treatment, and 1,200 tons of F035 solids were treated at a permitted facility. An additional 2,000 tons of arsenic -contaminated soils and debris were disposed of as special waste, the majority of which was from a residential cleanup at a property adjoining the site. Other areas of the site targeted for a future PRP-lead removal action have been stabilized with crushed rock to mitigate the off-site release of arsenic-contaminated runoff.
In February 2009, EPA and CSX Transportation, Inc. (CSXT) entered into an agreement where CSXT would perform the remaining removal activities under EPA oversight. CSXT and their contractors began work on Aug. 17, 2009. Current operations involve removal of equipment and other material left on-site when Kentucky Wood Preserving abandoned the site in 2006, as well as the demolition of all existing structures. The scope of work includes solidification of arsenic-contaminated soils on-site. The solidification process will prevent leaching of arsenic into surface water and groundwater and eliminate the potential for off-site migration of contaminants. Completion of removal activities required by EPA is targeted for the end of 2009. Following completion of on-site construction work, CSXT will apply for a restrictive covenant with KDEP to ensure that future land use is compatible with environmental conditions at the site.